Cleveland Board of Education v. LaFleur

414 U.S. 632 Supreme Court 1974
Whileanypregnant womanisfully capable ofdecidingwhen she returns to workorwhentoleavethestateunnecessarily penalizesher for asserting her right to bear children.

A teacher sued the Cleveland Board of Education for being required to take maternity leave, which she claimed violated the Due Process Clause of the 14th Amendment.

At the time, compulsory maternity leave rules were very restrictive, and the Cleveland Board of Education required pregnant teachers to take leave 5 months before childbirth.

The Supreme Court ruled in favor of Jo Carol Nesset-Sale (previously LaFleur), agreeing that mandatory maternity leave was unconstitutional. They claimed that overly restrictive maternity leave regulations could “constitute a heavy burden on the exercise of…protected freedoms” and personal choice relating to marriage and family life. This case preceded current family leave laws, such as the Family and Medical Leave Act of 1993.

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